Legionella risk assessment for Food production facilities
Updated 12 September 2026
Key points
- A legionella risk assessment is required for food production facilities premises under the Health and Safety at Work Act 1974 and the Approved Code of Practice L8
- Typical cost: £400 to £1500
- Review every 12 months, or sooner if the water system, its use, or the people using it change
- A named duty holder (usually the employer, landlord, or building operator) must arrange it and act on its findings
Food factories already live and breathe microbiological control, so the legionella duty often gets absorbed into the food safety system and then quietly lost. It should not be. Food hygiene law governs the water that touches the product; ACOP L8 governs the building water system that serves the people. The two regimes overlap in the same pipes but they have different duty holders, different control measures, and different evidence. A site that can show immaculate potable water records for product contact may still have no legionella risk assessment at all.
The distinctive risks in food production are the washdown systems and the refrigeration plant. Hose reels delivering warm or ambient water for cleaning down production areas are used at shift change, generate spray across the whole hall, and often stand idle between uses: a textbook aerosol source. Boot washers and equipment rinse points add more warm, intermittently used outlets. Many food plants cool their refrigeration with evaporative condensers, which are notifiable to the local authority as cooling towers and carry the full HSG274 Part 1 control regime of dosing, sampling, and documented cleaning.
Alongside the process plant sits the ordinary domestic system: staff showers, changing rooms, canteen, and handwash basins, all managed the same way as any commercial building. Third-party audit schemes increasingly ask for water hygiene evidence, so a legionella risk assessment and written scheme also protect the site's customer approvals, not just its legal position.
Is it legally required?
Food production premises are commercial premises under the Health and Safety at Work Act 1974 and ACOP L8. Evaporative condensers and cooling towers fall under the Notification of Cooling Towers and Evaporative Condensers Regulations 1992, and HSG274 Part 1 gives the technical guidance for those systems. Potable water requirements for product contact come from food hygiene legislation and are separate from, and additional to, the legionella duty.
Who is the duty holder?
The duty holder is whoever has control of the premises or the water system. For food production facilities premises, this is usually the employer, owner, landlord, or managing agent. The duty cannot be contracted out: you can hire a water hygiene consultant, but the legal responsibility still sits with you.
If you are unsure who holds the duty for your premises, see: Who is responsible for a legionella risk assessment?
What the assessment should cover
ACOP L8 sets out five things a suitable and sufficient assessment must do:
- Identify and assess sources of risk across the whole water system, including stored hot and cold water, dead legs, rarely used outlets, and any equipment that generates aerosols
- Produce a written scheme for preventing or controlling the risk, with specific tasks, temperatures, and frequencies
- Implement, manage, and monitor the scheme in practice, not just on paper
- Keep records of the assessment, the scheme, monitoring results, and any remedial action taken
- Appoint a competent person (often called the "responsible person") to be accountable for the scheme
Free legionella risk assessment template
A structured Word document following the five-step approach in ACOP L8. Covers risk identification, written scheme, monitoring, and records. If it isn't written down, you can't evidence it.
Follows ACoP L8 and HSG274 Part 2. Free. No spam.
Specific water system risks to check
For food production facilities premises, assessors typically pay close attention to:
- Hot water storage temperatures (calorifiers must reach 60°C throughout)
- Hot water distribution temperatures (50°C within one minute at outlets)
- Cold water storage tank condition, lid seal, and temperature (below 20°C)
- Dead legs, redundant pipework, and little-used outlets
- Shower heads, flexible hoses, and thermostatic mixing valves
- Any cooling tower, evaporative condenser, or spa pool (these are notifiable to the local authority under the Notification of Cooling Towers and Evaporative Condensers Regulations 1992)
How often to review
There is no fixed legal interval, but ACOP L8 requires that the assessment is reviewed regularly and whenever there is reason to believe it may no longer be valid. For most food production facilities premises, that means at least every 12 months and sooner after any of the following:
- Changes to the water system (new pipework, fittings, equipment)
- Changes to the use of the building or the number of occupants
- A positive legionella test result or a case of Legionnaires' disease linked to the premises
- Prolonged periods of low occupancy or system shutdown (a risk during holidays, term breaks, or refurbishment)
- New guidance from HSE
Typical cost
A professional legionella risk assessment for food production facilities premises typically costs between £400 and £1500, depending on the size of the building, the number of water outlets, and whether there are any cooling towers or evaporative condensers (these add significantly to the cost because of the statutory inspection regime).
Use our cost calculator for an estimate based on your specific water system.
Need a legionella risk assessment for your premises? We will be partnering with Legionella Control Association registered providers shortly.
Free legionella risk assessment template
A structured Word document following the five-step approach in ACOP L8. Covers risk identification, written scheme, monitoring, and records. If it isn't written down, you can't evidence it.
Follows ACoP L8 and HSG274 Part 2. Free. No spam.